AML Policy

Policy Statement

Deniba International Exchange (hereafter referred as ‘DIE’) is committed to and conducts its business activities lawfully and in a manner that is consistent with its compliance obligations issued by Central Bank of UAE Standards, MENAFATF, and other significant international organizations to fight against Money Laundering, Terrorist Funding activities and financing of illegal organizations. We reflect that by enforcing robust compliance policies and procedures across all our branches & our office along with cutting edge software.

DIE’s Decree Compliant Declarations

DIE abides and complies to all the laws stipulated under Federal Decree-law No. (20) of 2018 and other mandatory regulations and Notices issued by CBUAE from time to time.

DIE has all the relevant and stringent practices placed in our organization which are recommended by FATF, MENAFATF, Egmont Group & others.

DIE also complies to all the sanction laws and regulations of the CB-UAE laws, EU, OFAC, UN, UK as applicable.

KYC Process

DIE sedulously carries out its KYC process for all its legal persons and legal entities by obtaining, updating, and maintaining Customer Identification (CID), Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) process.

Customer IDs are checked, validated, and recorded into our internal system.

Customer Due Diligence is conducted as a measure for gathering additional information while from new/existing customer- Individual or Corporate.

Enhanced Due Diligence is including but not limited to conducting when the transactions appear to be or are suspicious in nature basis our internal set rules for raising red flags. More valid documents are requested for such as proof of income, UBO details, source of funds, etc.

DIE establishes and records the true identity of prospective customers/beneficial owners prior to onboarding or establishing a business relationship. These are being done by gathering the minimum information required based on customer’s Risk Class, and validating this information against valid identification documents and other supporting documents.

Anonymous accounts or those under fictitious names and all other similar accounts shall be absolutely prohibited. Likewise, DIE prohibits accounts / relationship with Shell Banks and companies.

DIE policy clearly states that prior management approvals to be taken before dealing with PEP/FPEP/HIO.

Transaction Monitoring & Reporting

Transaction monitoring is attentively done to make sure that the transactions are always in line with the customer’s profile.

For individuals – Keeping up to date KYC profile.

For corporates – Making sure the transactions in line with the business profile, nature, size and complexities.

Third Party Transactions- Meticulously monitored for every transaction against defined rules.

Suspicious transactions; after thorough investigations are reported to the CBUAE- FIU.

DIE has a strict rule to report suspicious transactions or activities instantaneously to the compliance department at all levels- Customer serving staff, Operations, Board of Directors, Compliance Team without any delay.

Know your Employee & Employee Training

DIE HR policy clearly states that each staff member has to provide legal, valid, and attested documents to confirm that they are reliable and has no reason to not employ them in line with MoL.

AML/CFT training is given to each employee within 30 days of joining. In-house training and assessments are done periodically and is a mandate for all DIE employees, regardless the designation or tenure.

Refreshers training is given when there are changes in AML law and regulations or DIE’s internal policies.

DIE also cascades information with regard to new/updated AML rules and regulations to all the employees at all times.

Record Keeping & Internal Audit Function

DIE records, maintains and retains all the customers’ data including profile, transactions data, any other customer related data for a period of minimum 5 years.

DIE Internal Audit function monitors and evaluate DIEs internal control environment for its adequacy, efficiency and effectiveness.